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K–12 Education: DOD Needs to Assess Its Capacity to Provide Mental Health Services to Students
GAO-25-107247
May 14, 2025
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7 Open Recommendations
Agency Affected Recommendation Status
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to develop and disseminate guidance to schools for assigning standardized testing coordination responsibilities to school leaders. This guidance should discourage schools from relying on school counselors as standardized testing coordinators. (Recommendation 1)
Open
DOD partially concurred with this recommendation. DOD stated that it will direct DODEA to develop and disseminate guidance on assigning testing coordination responsibilities in a way that is mindful of school counselors' primary responsibilities. Our report noted that encouraging school leaders not to assign standardized testing coordination duties to school counselors, in line with the position of the American School Counselor Association, could help address some of DODEA's workload capacity issues. We continue to maintain that guidance to explicitly discourage assigning testing responsibilities to school counselors is warranted.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to assess the capacity of its workforce to provide the continuum of behavioral supports indicated in its MTSS framework. This assessment should consider the capacity of school psychologists and school counselors. (Recommendation 2)
Open
DOD partially concurred with this recommendation. DOD said it has assessed school-level staffing to ensure responsibilities are appropriately positioned to support the strategic instructional needs of military-connected students, and noted that student support is not limited to school counselors and psychologists. Rather, it involves a comprehensive team of school nurses, school social workers, and other professionals committed to student success. We agree, and note that the recommendation does not preclude taking a broader approach as DOD outlines.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the DODEA Director to develop a plan based on the results of its workforce assessment to address any identified gaps in workforce capacity that could hinder the success of its MTSS initiative. (Recommendation 3)
Open
DOD partially concurred with this recommendation. DOD stated that the MTSS framework is meant to be adaptable to enable DOD to meet the ever-evolving needs of its schools and students. DOD also noted that the next phase of the MTSS rollout will focus on refining roles and responsibilities to ensure optimized resource allocation, and that MTSS requires cycles of continuous assessment. We agree that optimizing resource allocation is critical to the success of MTSS. However, DODEA has not yet assessed its capacity to implement all aspects of the MTSS initiative. We continue to believe that identifying any gaps in workforce capacity and developing a plan to address them will help DODEA align its staffing resources to meet students' needs and improve the success of its MTSS implementation.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the Director of Military Community Support Programs to evaluate the MFLC program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 4)
Open
DOD agreed with this recommendation. DOD has an ongoing multi-step project to assess the MFLC program's use and effectiveness across all locations. The project includes locations where Child and Youth Behavioral (CYB)-MFLCs serve military children. DOD also noted a recent report commissioned by Military Community Support Programs that examined military-connected children in military child development centers, youth programs and schools with military populations served by CYB-MFLCs. We await further progress on this recommendation.
Department of Defense The Secretary of the Army should direct the Director of the Directorate of Prevention, Resilience, and Readiness to evaluate the ASACS program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 5)
Open
DOD did not agree with this recommendation. DOD stated that, in the context of ongoing work to implement ASACS program guidance, ASACS staff in DODEA schools will collaborate with local DODEA school leaders and counselors for effective collaborative planning. Because this work is ongoing, DOD believes this recommendation is superfluous. While it is encouraging that the Army recognizes the value of collaboration, the ASACS program has not been evaluated for effectiveness in DODEA schools, and Army officials agreed that a formal program evaluation was needed. We continue to maintain that an evaluation of the ASACS program is necessary.
Department of Defense The Deputy Under Secretary of Defense for Personnel and Readiness should direct the Director of the Defense Health Agency to evaluate the School Behavioral Health program's use in DODEA schools, seeking feedback from DODEA headquarters staff and school leaders, and develop a plan to address any areas of concern identified through its evaluation. (Recommendation 6)
Open
DOD agreed with this recommendation. DOD stated that evaluating the program - including obtaining feedback from DODEA leaders and other stakeholders - is essential to program development, sustainment and efficiency. We await further progress on this recommendation.

Special Education: Improved Allocation of Resources Could Help DOD Education Activity Better Meet Students' Needs
GAO-25-107053
Apr 17, 2025
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5 Open Recommendations
Agency Affected Recommendation Status
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to revise its special education staffing formulas to incorporate students' service minute requirements specified in IEPs among the factors it considers. (Recommendation 1)
Open
DOD partially concurred with this recommendation. The agency acknowledged the importance of aligning staffing practices with the diverse needs of students with IEPs, and that service minutes can provide valuable insights into students' needs. DOD also stated that it will reassess its staffing formulas and employ a data-informed approach in doing so. However, DOD said that aligning staffing to service minutes may lead to various challenges-including overstaffing-as service minutes may not always accurately reflect the actual needs of students and may fail to account for the individualized nature of each student's educational requirements. We agree that staffing practices should take students' needs into account. Further, the purpose of an IEP is to lay out the special education and related services tailored to an individual student's needs and the anticipated frequency, location, and duration of those services. We continue to believe that required service minutes are one of the factors the agency should consider in its staffing formulas. Further, considering this information would support DOD's efforts to use a data-informed approach in its staffing practices.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to ensure that any special education paraeducators who work with students who may need behavioral supports receive crisis training. (Recommendation 2)
Open
DOD partially concurred with this recommendation and noted ongoing efforts to expand its crisis training contract. DOD also stated that crisis training is not applicable to every paraeducator role within DOD schools; it also acknowledged the necessity of providing access to crisis training to paraeducators and other key personnel serving students with significant behavioral challenges. We will monitor the agency's efforts to target crisis training to those who need it.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to provide supplemental instructional materials to special education teachers agencywide to help them adapt the general education curriculum for students with IEPs. (Recommendation 3)
Open
DOD partially concurred with this recommendation. DOD stated that relying solely on supplemental instructional materials would not fully ensure that it exposes students to core standards alongside their nondisabled peers, adequately prepares students for general education assessments, or meets the individualized needs of students. We agree that teachers should not solely rely on supplemental materials: this recommendation does not state that teachers should do so. We also acknowledge that DOD faces unique requirements regarding the procurement of educational resources and agree that it needs a strategic approach to ensure that it acquires resources that effectively address students' needs moving forward. As such, we continue to believe that agencywide access to supplemental instructional materials would expand the resources available to DODEA teachers to support their students and would continue to allow teachers to tailor instructional materials based onstudents' unique needs.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to make more specialized reading interventions accessible across all DODEA locations to students with specific learning disabilities, including dyslexia, that impact their ability to read. (Recommendation 4)
Open
DOD partially concurred with this recommendation. DOD said that the agency already systemically provides students with reading interventions. While DODEA provides some reading interventions that all schools can access, DODEA district and regional officials told us that it is difficult to obtain more specialized reading interventions for students receiving special education overseas, and that some schools and districts have access to more specialized interventions while others do not. We therefore continue to believe that implementing this recommendation would help ensure that students receiving special education and related services develop to their fullest potential, regardless of their location.
Department of Defense The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the DODEA Director to communicate its timeframes for its new procedural guidance on special education and what resources staff should use to interpret the DOD policy while that guidance is being developed. (Recommendation 5)
Open
DOD partially concurred with this recommendation and stated that it is committed to issuing updated guidance beginning in the 2025-2026 school year. DOD said it will take a phased approach to update and implement the guidance, including communicating with staff about prior guidance that should not be used. DOD also said that existing agency policy provides guidance on special education. However, we reported that all school staff we spoke with said that DOD policy is not clear or detailed enough to help them implement it without guidance. We agree with DOD's plan to phase in new guidance, and maintain that it is important for DOD to communicate which resources staff should use to interpret DOD policy in the interim.

Department of Education: Preliminary Results Show Strong Leadership Needed to Address Serious Student Aid System Weaknesses
GAO-24-107783
Sep 24, 2024
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5 Open Recommendations
3 Priority
Agency Affected Recommendation Status
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to (1) expeditiously develop a plan that tailors the agency's guidance on identifying and managing requirements to fit its current incremental deployment approach and (2) implement the plan thereafter. (Recommendation 1)
Open
In April 2025, FSA stated that the Office of Student Aid Program Management, the office responsible for FAFSA development, uses modern tools to manage incremental deployment and provide visibility into progress of development over time. They did not further discuss any actions they have taken or plan to take to develop a plan that would document their use of the tools to manage development of the FAFSA form. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education
Priority Rec.
The Secretary of Education should direct the Chief Operating Officer of FSA to (1) expeditiously develop a plan that tailors the agency's guidance on system testing to fit its current incremental deployment approach and (2) implement the plan thereafter. (Recommendation 2)
Open
In April 2025, FSA stated that the Office of Student Aid Program Management has a detailed, layered testing plan to ensure confidence in the FAFSA. We will update the status of the recommendation once FSA provides the plan and we are able to evaluate whether it addresses the recommendation.
Department of Education
Priority Rec.
The Secretary of Education should direct the Chief Operating Officer of FSA to expeditiously (1) develop an FSA policy on standards for IV&V independence and (2) ensure that FPS IV&V agents meet those standards. In developing the policy, FSA should define the degree of technical, managerial, and financial independence required of the personnel or agents performing IV&V. (Recommendation 3)
Open
In April 2025, FSA stated that it has hired a new digital services team to provide better oversight of development. These team members, and others, according to the agency, are the primary technical product managers and engineers capable of reviewing code and ensuring competent delivery. However, FSA did not comment on the actions they have taken or plan to take to develop a policy on IV&V independence standards. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education The Secretary of Education should direct the Chief Operating Officer of FSA to expeditiously (1) develop an FSA policy requiring that projects determine and document the appropriate scope of IV&V efforts and (2) ensure that the FPS project follows this policy. In developing the policy, FSA should require that projects consider IV&V activities across the acquisition lifecycle. (Recommendation 4)
Open
In April 2025, FSA stated that all systems that impact the FAFSA form are reviewed by internal technical talent before release and go through the technical release management process to ensure high-quality deployment. However, the agency did not comment on the actions they have taken or plan to take to develop a policy requiring that projects determine and document the appropriate scope of IV&V efforts. We will continue to monitor FSA's actions to implement this recommendation.
Department of Education
Priority Rec.
The Secretary of Education should expeditiously (1) assess the role of the department's and FSA's CIOs in the continuing development of FPS, and (2) based on that assessment, develop and implement a plan for providing the department's CIO with a significant role in the governance and oversight of FPS while clarifying the responsibilities between the departmental and agency CIO. (Recommendation 6)
Open
In September 2024, FSA announced that the agency had begun recruiting for a new Chief Technology Officer (CTO) that would replace FSA's Chief Information Officer (CIO) role. According to the agency, this would ensure that there is only one CIO position in the Department of Education (Education). According to FSA, both the Education CIO and the FSA CTO play a crucial role in the ongoing governance and oversight of the FAFSA through frequent engagement with the Executive Director for Student Aid Program Management. FSA did not comment on the actions it has or planned to take to develop and implement a plan for providing the department's CIO with a significant role in the governance and oversight of FPS. We will continue to evaluate the department's progress in implementing this recommendation.

FAFSA: Education Needs to Improve Communications and Support Around the Free Application for Federal Student Aid
GAO-24-107407
Sep 24, 2024
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7 Open Recommendations
1 Priority
Agency Affected Recommendation Status
Office of Federal Student Aid The Chief Operating Officer of the Office of Federal Student Aid should develop an outreach strategy to identify and connect with students who did not submit a FAFSA application this cycle (2024-25) due to delays and technical issues, and to provide them with the information they need to apply during the upcoming cycle (2025-26). (Recommendation 1)
Open
The Department of Education will provide information on how it plans to address this recommendation by April 2025.
Office of Federal Student Aid
Priority Rec.
The Chief Operating Officer of the Office of Federal Student Aid should review the FAFSA application process to identify ways to reduce the burden on students and families by addressing the remaining technical issues and streamlining the process for parent or spouse contributors to reduce the total time it takes to complete the FAFSA form. (Recommendation 2)
Open
Education neither agreed nor disagreed with this recommendation. In January 2025, Education officials reported that FSA had implemented changes to improve the user experience and streamline the completion of the FAFSA. However, multiple technical issues remain that continue to affect some students and their families, making it harder for them to complete a FAFSA. This includes certain problems entering a spouse's financial information into the application, occasional roadblocks that prohibit students from proceeding to the next section of the form, and disappearing fields when students try to make a correction. Education still must take action to address these remaining technical issues and review the FAFSA application process to identify additional ways to reduce the burden on students and families. Implementing this recommendation will make it easier for students to apply for and obtain the financial assistance they need to afford college.
Office of Federal Student Aid The Chief Operating Officer of the Office of Federal Student Aid should overhaul its submission process for students whose parent or spouse contributors do not have Social Security numbers to address additional application barriers. This should include making the identity verification process more efficient and determining how to use Individual Taxpayer Identification Numbers to transfer this population's tax data from the IRS. (Recommendation 3)
Open
The Department of Education will provide information on how it plans to address this recommendation by April 2025.
Office of Federal Student Aid The Chief Operating Officer of the Office of Federal Student Aid should improve translation services by providing a clear path to support for languages other than English and Spanish through the call center menu and progress toward making the FAFSA application available in languages other than English and Spanish. (Recommendation 4)
Open
The Department of Education will provide information on how it plans to address this recommendation by April 2025.
Office of Federal Student Aid The Chief Operating Officer of the Office of Federal Student Aid should plan for and ensure hiring of sufficient staff to increase capacity at the Federal Student Aid Information Center call center to be able to meet call demand and improve customer service. (Recommendation 5)
Open
The Department of Education will provide information on how it plans to address this recommendation by April 2025.
Office of Federal Student Aid The Chief Operating Officer of the Office of Federal Student Aid should develop a comprehensive plan for providing FAFSA applicants with timely updates on the status of their application and solutions to technical barriers. (Recommendation 6)
Open
The Department of Education will provide information on how it plans to address this recommendation by April 2025.
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